In the Lynde v. Lynde case of 1900, the U.S Supreme Court was tasked with determining whether a New York court had jurisdiction over a divorce proceeding involving non-residents. The couple in question were residents of Wisconsin but Mrs. Lynde left her husband and moved to New York where she filed for divorce on grounds of abandonment and failure to provide support. Mr. Lynde contested this, arguing that since they were not residents of New York, the courts there did not have jurisdiction over their marital status. The Supreme Court ruled in favor of Mr.Lynde stating that while states generally have broad powers under their police authority to regulate domestic relations among its inhabitants, those powers do not extend beyond its borders unless both parties are personally within its territory at the time proceedings commence or consent is given by absent party for such proceedings. This ruling set an important precedent regarding state jurisdiction over personal matters like marriage and divorce which has influenced subsequent family law cases across different states.

In the dissenting opinion for Lynde v. Lynde, Justice Harlan argued that the court should not have jurisdiction over this case as it was a matter of domestic relations, traditionally left to state courts. He believed that federal courts should only intervene in such cases when there is clear evidence of abuse or neglect by state authorities. Furthermore, he disagreed with the majority's interpretation of Mrs. Lynde's rights under her husband's will and felt they had failed to properly consider relevant New York laws governing inheritance and property rights within marriage. In his view, Mrs. Lynne was entitled to more than just income from her late husband’s estate; she also had a right to access its capital value if necessary for her support.